Reprice 5-year FD ladder ahead of BNM MPC

Auto-generated from RPPA, LTRA agents based on the prior 24-hour signal window.


Consolidate 4 Klang Valley branches into 1 flagship

Auto-generated from BPPA, BWOA agents based on the prior 24-hour signal window.


Add overlay rules to AML model on cross-border SME flows

Auto-generated from OPRA agents based on the prior 24-hour signal window.


Pre-fund Sabah branch ATMs ahead of long weekend

Auto-generated from LTRA, BWOA agents based on the prior 24-hour signal window.


Escalate 3 SME RMs leaving for competitor

Auto-generated from BWOA, BPPA agents based on the prior 24-hour signal window.


Maybank moved 5Y FD to 4.20% on 21-May (15bps gap to us); BNM MPC minutes due today 17:00. Early-signal stage — Pricing wants to wait for minutes, Treasury wants stress run before any move.

Maybank's 15bps move yesterday is the first signal — wait for MPC minutes at 17:00 before repricing

Maybank moved 5Y FD from 4.05% to 4.20% on 21-May, opening a 15bps gap. Historically (since 2022), Maybank moves first and CIMB follows within 2-4 days in 7 of 9 prior episodes. Our 14-day net flow remains positive (+RM 38M) so churn risk is low for another 48-72h. Recommend hold-and-watch until BNM MPC minutes release at 17:00.

Maybank 5Y board 4.20% effective 21-May 14:00; our board 4.05%

Historic competitor follow-on lag (2022-2025): CIMB follows Maybank 5Y move in 2.4 days median (7 of 9 episodes)

14-day net 5Y flow: +RM 38M (still positive but trend deceleration -RM 4.5M/day)

BNM MPC minutes scheduled release: 22-May 17:00 — drives 18bp avg market reaction on hawkish signal

Repricing latency cost (model): RM 0.4M/day at current gap, accelerates to RM 0.7M/day if gap widens > 18bps

Hold 5Y board at 4.05% pending MPC minutes; pre-stage reprice memo for Wed if minutes are hawkish

Increase competitor scrape from 6-hourly to 2-hourly through Thu

Brief CEO chief-of-staff at 16:00 ahead of MPC release

If MPC minutes are dovish (estimated 25% probability), holding is correct and we avoid a costly retraction. If hawkish (75%), we lose 24-36h of repricing window but our retention model says churn is bounded at -RM 90M while gap stays < 18bps.

Run IRRBB stress before any reprice — SOT already at 14.2% of T1

IRRBB SOT sitting at 14.2% of T1 against the 15% Basel limit means any 5Y inflow surge needs to be modelled before we commit to a board change. EVE sensitivity at +25bps is -RM 218M today. Treasury wants a 200-path stress run completed before ALCO authorises any pricing move — that takes 36 hours from data cut.

IRRBB SOT 14.2% T1; soft trigger 14.0% already breached on 19-May

EVE at +25bps: -RM 218M; at +50bps: -RM 412M; both within Risk Appetite but trending up

Banking book duration gap 1.4y (soft limit 1.2y)

Last 200-path Monte Carlo was 14-May — pre-Maybank-move and pre-MPC-minutes

Basel IRRBB CP: 30-day notification required if SOT breaches 15%

Kick off 200-path Monte Carlo IRRBB stress run today 14:00 with post-MPC scenario branches

Pre-stage RM 600M MGS sell-down ticket with Group Treasury as contingent hedge

Block any pricing change request until stress run is signed off

If we reprice without the stress refresh, ALCO governance review (scheduled 28-May) could flag a control gap — minor finding but reportable to BNM in Pillar 2 self-assessment.

Competitor 5Y FD board spread vs ours (bps)

Maybank's 21-May move was the first breach of 15bps trigger in 6 months.


Quarterly branch portfolio review flagged the Klang Valley 4-branch cluster again at 28% trailing utilisation. Network wants to act before lease renewal cycle; Branch flags HR/union prep not started.

4th consecutive quarterly review flagging the cluster — lease renewals on 2 sites due Q3

This is the 4th quarterly review (since Q3-2025) where the Bangsar/Damansara Uptown/Mont Kiara/TTDI cluster has been flagged. Two of the four leases come up for renewal in Q3-2026 (Bangsar 15-Sep, Mont Kiara 28-Aug) with landlord-proposed rent increases of 8-12%. Network strategy view: this is the natural decision window; missing it means another 5-year lock-in on under-utilised footprint.

Quarterly portfolio review log: Q3-2025, Q4-2025, Q1-2026, Q2-2026 — same cluster flagged all 4 cycles

Lease renewal: Bangsar expires 15-Sep-2026 (+12% rent ask), Mont Kiara expires 28-Aug-2026 (+8% rent ask)

Trailing 90-day utilisation: 28% (network median 71%)

1 Utama flagship site under exclusivity option until 28-May (Sunway REIT)

FSA s.39 90-day notice — would need to file by 31-May to meet Bangsar lease end

Commission updated flagship business case with Q2-2026 numbers (currently using Q1)

Begin BNM informal pre-consultation (BNM Branch Network Unit) this week

Request lease landlord exclusivity extension to 14-Jun

If we miss this window, next opportunity is Q3-2027 when remaining 2 leases come due — 12 months of carrying RM 14.6M of foregone savings = ~RM 14.6M opportunity cost.

HR/NUBE prep not started — 14-day IRA consultation clock means action needed this week

If Network gets ALCO approval next week, the Industrial Relations Act 2024 14-day consultation clock means NUBE must be engaged by 26-May to keep the timeline whole. HR has not begun roster impact analysis or staff communication prep. Branch wants to escalate so HR commits resources before Network commits to a date.

IRA 2024 amendment: 14-day notice of redeployment terms required before closure announcement

HR resource constraint: 2 HRBPs on leave through 29-May; remaining 1 HRBP supports SME segment

Staff headcount inventory not yet finalised (4 branches × ~9-10 staff each, headcount drift since Q1)

Sunway Pyramid + Subang Jaya open req status to be confirmed

NUBE has not been informally pre-briefed on this specific cluster

Lock HRBP capacity (request 1 additional HRBP backfill from group HR) by Mon

Complete staff headcount inventory across 4 branches by Tue

Schedule NUBE informal pre-brief for 25-May (post-ALCO decision)

If HRBP capacity not secured, NUBE engagement slips and the IRA 14-day window pushes closure announcement into June — risking overlap with the BNM Pillar 2 supervisory review starting 8-June.

4-branch cluster utilisation (% vs network median)

Cluster utilisation drifting lower; 4th consecutive quarterly review flag.


Trailing 14-day AML alerts on Johor→Vietnam corridor at 14 vs baseline 4. Pattern match score 0.76 (below 0.80 EDD trigger). Risk wants to escalate to FCC ops review before overlay rule commit.

Pattern match score at 0.76 — below EDD trigger but trend is one-way

Pattern match score sits at 0.76 against FATF TM-2024-07, climbing 0.05 over the past 4 days. AML alerts at 14 vs baseline 4 already justify FCC ops review; deploying overlay rules pre-emptively (i.e., before crossing 0.80) is allowed under our internal AML model governance policy but requires FCC head sign-off. Risk recommends escalation to FCC head and ALCO joint review before commit.

Pattern match score: 0.76 (climbed 0.05 in 4 days)

AML alerts trailing 14d: 14 (baseline 4 over 90d; z-score 4.2)

FCC ops capacity: 84% load — additional 18% alert volume from overlay push utilisation to 99%

Internal AML governance policy v2.3: pre-emptive overlay deployment requires FCC head + Risk head joint sign-off

BNM AMLA s.16 EDD trigger: 0.80 pattern match (internal calibration)

Escalate to FCC head + Risk head joint review meeting Mon 09:00

Pre-stage overlay rule v4.1 in shadow mode for FCC team to inspect alert quality

Maintain enhanced monitoring on 14 flagged accounts pending decision

If we escalate but don't commit by Wed, pattern match score is on track to cross 0.80 by 23-May, at which point EDD becomes mandatory and we lose the 'pre-emptive' framing — STR clock starts and we are reactive instead of proactive.

Daily AML alerts — Johor→Vietnam SME corridor

Alert volume drifting upward; pattern match score still below 0.80 EDD trigger.


Tadau Kaamatan still 8 days away; Treasury monitoring withdrawal pattern but no action needed until withdrawal volume crosses RM 5M daily trigger.

Volume at 4.5x average but still below RM 5M trigger — monitor through weekend

Daily Sabah ATM withdrawal volume sits at RM 4.5M, 12% above network average but still below the RM 5M trigger that initiates the Tadau loading playbook. CIT booking lead time of 5 working days means we have until Tue 26-May to commit. Treasury's recommendation is to defer until the weekend withdrawal print on 24-May, which historically gives the cleanest read on whether the Tadau multiplier will track 3.5x or soften.

Sabah ATM withdrawal volume: RM 4.5M/day (12% above network average)

Loading playbook trigger: RM 5M/day sustained for 2 days

G4S CIT booking lead: 5 working days → Tue 26-May deadline for Thu 28-May loading

Weekend 24-May print historically predictive of Tadau multiplier (R^2 0.78 vs 2022-2025)

BNM cash centre KK: last drawdown 19-May RM 22M, headroom RM 18M for additional draw

Continue monitoring; trigger Tadau loading playbook if 5M crossed Sat or Sun

Pre-engage G4S Sabah on tentative Thu 28-May booking slot

No customer or branch communication required at this stage

Low risk at this stage — even if we miss the Tue deadline, contingent 3-day-lead booking option exists at RM 60k premium. Bigger risk is operational fatigue if we trigger the playbook every year on T-8 day without need.

Sabah ATM daily withdrawal volume (RM M)

Volume on monotonic upward trend; trigger threshold not yet sustained.


OCBC announced Penang SME expansion via Bursa filing on 19-May (target 25 RM hires by Q3). RM attrition risk model elevated; no confirmed resignations yet.

OCBC Bursa filing flagged Penang SME expansion — attrition model elevated, no resignations yet

OCBC's 19-May Bursa filing announced a Penang SME expansion targeting 25 RM hires by Q3. Our RM attrition risk model lifted from 48 to 61 over 3 days based on (a) competitor expansion signal, (b) CRM social-signal scrape showing 6 of our Penang SME RMs viewed OCBC career page in the last 7 days, and (c) 2024 HSBC analogue pattern. No confirmed resignations yet — recommend escalating to Head of SME for preemptive retention conversation pool.

OCBC Bursa filing 19-May: Penang SME expansion, target 25 RM hires by Q3

RM attrition risk model: 61 (3-day lift from 48; trigger 70)

CRM social-signal scrape: 6 of 23 Penang SME RMs viewed OCBC career page in trailing 7 days

2024 HSBC analogue: similar Bursa announcement preceded confirmed RM poach by 18 days

Counter-offer pool available without HR Committee escalation: RM 600k (covers ~2 RMs at 1.4x base)

Brief Head of SME Mon 09:00 — initiate informal retention conversations with top 6 Penang SME RMs

Pre-stage counter-offer scenarios for top 3 RMs (Tan, Lim, Goh — highest portfolio + highest social-signal activity)

Increase CRM social-signal scrape cadence from weekly to daily for Penang SME team

If retention conversations don't happen this week, we run the 2024 HSBC analogue: 18-day window to confirmed resignations. Cost of inaction estimated at RM 6-12M depending on portfolio defection severity.

Bring Batu Kawan satellite desk forward in roadmap — competitor signal makes the business case

OCBC's expansion announcement converts Batu Kawan from 'roadmap item' to 'defensive move'. Network strategy team has had the business case 80% complete since Q4-2025 (capex RM 0.8M, Y1 opex RM 0.6M, time-to-RM-50M-deposit 4-6 months). Bringing it forward now sends a market signal that we are doubling down on Penang SME, which has a calming effect on at-risk RMs. Recommend escalating to CEO at next ALCO.

Batu Kawan satellite SME desk business case 80% complete (Q4-2025 work paused)

Capex RM 0.8M; Y1 opex RM 0.6M; time-to-revenue 4-6 months

Penang FTZ concentration: 100% of top-FTZ-SME accounts at Bayan Lepas branch

OCBC Bursa filing 19-May: 25 RM hires by Q3 — implies aggressive market share play

MIDA Batu Kawan industrial park MoU: signed 2024, refresh due Jun-2026

Refresh Batu Kawan satellite SME desk business case with current numbers by Fri

Pre-brief CEO chief-of-staff ahead of next ALCO (28-May)

Engage MIDA on Batu Kawan MoU refresh timing

If Batu Kawan is delayed beyond Q3, OCBC builds first-mover momentum in the corridor — recovery in 2027 is possible but at higher cost (estimated RM 0.4-0.8M brand reset).

Penang SME RM attrition risk score (model output 0-100)

OCBC Bursa filing 19-May broke the score above trend; trigger threshold not yet breached but trajectory is steep.


Competitor moves accelerating (CIMB to 4.25% on 23-May) and BNM MPC minutes released yesterday lean hawkish. Pricing wants reprice now; Treasury flags duration impact needs ALCO sign-off before Wed.

CIMB jumped to 4.25% this morning — our 20bps gap is now the widest in 6 months

CIMB 5Y board moved 4.05%→4.25% at 09:30 today, widening our gap to 20bps from 15bps yesterday. Trailing 14-day net flow on the 5Y bucket turned negative for the first time since Q3-2025 (-RM 184M). Retention model predicts a further -RM 320M outflow over the next 10 days if we hold, dominated by 8 large corporate treasury depositors in Penang and KL who shop boards weekly.

CIMB 5Y board 4.25% effective today 09:30 (Maybank already at 4.20% since 21-May)

Our 5Y net flow trailing 14 days: -RM 184M (vs +RM 92M average prior 90 days)

8 corporate treasury accounts > RM 50M each flagged by RM CRM as 'rate-shopping' in last 5 days

BNM MPC minutes 22-May: hawkish tone on core CPI; OIS prices +25bps at 88% probability

Repricing latency cost model: every 24h delay = RM 0.7M foregone NIM on inflow lost to competitors

Escalate to ALCO chair tonight; request emergency convening Tue 16:00 for Wed 08:00 board change

Draft customer communication for top 380 5Y depositors (>RM 2M) ready for RM-led outbound

Lock competitor scrape cadence to 2-hourly until post-MPC

Delay risk: every 24h costs ~RM 0.7M in foregone NIM and risks losing the 8 corporate treasury accounts (RM 620M combined) to Maybank/CIMB, which would be unrecoverable for 90 days under their typical lock-in terms.

Duration impact needs ALCO sign-off — IRRBB SOT already at 14.2% vs 15% limit

Pricing's proposed +20bps on 5Y will pull RM 1.9bn into the 5Y bucket and tighten EVE sensitivity, but IRRBB SOT is already at 14.2% of T1 (limit 15%). Net effect of the reprice is positive (SOT falls to ~13.0%), but the transition path during the 6-week pull-through window is non-monotonic — sims show a 9-day window where SOT could touch 14.7% if inflows are front-loaded.

IRRBB SOT 14.2% T1; internal soft trigger 14.0% (already breached)

EVE sensitivity at +25bps: -RM 218M; at +50bps: -RM 412M

Transition sim: SOT peak 14.7% on Day 9 of pull-through (8% probability of touching 15%)

LCR 138%, NSFR 116% — no liquidity constraint on the move

Basel III IRRBB CP requires 30-day notice to BNM if SOT > 15% breached

Run 200-path Monte Carlo on SOT transition tonight; circulate to ALCO Tue 14:00

Pre-clear contingent MGS sell-down (RM 600M) with Group Treasury as SOT hedge

Flag BNM ASD desk informally that an IRRBB profile change is imminent

8% probability the SOT touches 15% during pull-through — would force a 30-day BNM notification under IRRBB CP 2023 and could attract supervisory scrutiny in the upcoming Pillar 2 review.

CIMB move this morning pushed spread to 20bps — second consecutive day above 15bps trigger.


Cluster utilisation now 7th consecutive day below 30%, flagship lease offer expires 25-May. Network wants commit; Branch flags NUBE consultation needs to land first.

1 Utama flagship lease offer expires Mon — losing this site delays consolidation 5-8 months

Landlord (Sunway REIT) lease offer for 1 Utama anchor unit expires Mon 25-May 17:00 at RM 188k/month with 5+5 term and 2-month fit-out grace. Comparable premium locations (Pavilion KL, IOI City) priced 14-22% higher with shorter grace periods. Cluster utilisation is now 27% on trailing 7 days — well below the 50% network trigger.

1 Utama lease offer: RM 188k/month, 5+5, 2-month fit-out grace; expires 25-May 17:00

Comparables: Pavilion KL RM 224k/month (+19%), IOI City RM 215k/month (+14%), Mid Valley RM 240k/month (+28%)

Cluster utilisation 7-day trailing: 27% (network median 71%)

FSA s.39 closure notice 90-day clock starts on filing — every week of delay pushes go-live by 1 week

Customer overlap analysis stable: 62% transact at 2+ branches

Request 48-hour extension on Sunway REIT offer pending ALCO Tue (escalation to MD level)

Pre-stage FSA s.39 filing pack for immediate submission post-approval

Loop in MIDA for Bumiputera workforce sign-off ahead of formal announcement

If lease expires unrenewed (estimated 30% probability without ALCO go-ahead), next-best site adds RM 0.5-1.1M annualised rent and 5-8 months delay — payback extends from 7 to ~10 months but still positive.

NUBE consultation lands 27-May — need redeployment letters drafted by then or risk industrial action

NUBE pre-engagement on 21-May was constructive but formal consultation under Industrial Relations Act 2024 amendment requires 14-day notice of redeployment terms before any branch closure announcement. If we commit to closure on 24-May without redeployment letters drafted, the timeline collapses — NUBE has signalled it will treat this as a procedural breach and may file a trade dispute under IRA s.18.

NUBE pre-engagement 21-May: constructive, subject to redeployment terms for non-VSS staff

IRA 2024 amendment: 14-day notice of redeployment terms required before closure announcement

Redeployment letter drafts currently 60% complete (24 of 38 staff)

Sunway Pyramid + Subang Jaya open reqs confirmed open through end-June

VSS terms benchmarked vs 2024 JB consolidation (6 months pay + accrued leave + retraining allowance)

Complete remaining 14 redeployment letter drafts by Sun 24-May 18:00

Confirm Sunway/Subang open req holds with HR business partner Mon morning

Schedule NUBE formal consultation 27-May 10:00 — written agenda by Mon 09:00

20% probability NUBE files IRA s.18 trade dispute if letters not ready by 27-May — would freeze closure process for 60-90 days and risk media attention during the BNM Pillar 2 review window.

Sixth consecutive day below 30%; lease decision window closes Mon 25-May.


Alert volume now 5x baseline on Johor→Vietnam corridor; pattern match score with FATF TM-2024-07 climbed from 0.71 to 0.82 over 5 days.

Pattern match score climbed to 0.82 — corridor flow now meets BNM AMLA 'reasonable suspicion' threshold

Pattern match to FATF TM-2024-07 (trade-based ML via electronics re-export) advanced from 0.71 to 0.82 over the trailing 5 days as more accounts surfaced sharing the same HCMC beneficiary network. BNM AMLA guidance treats pattern match > 0.80 as 'reasonable suspicion' triggering EDD obligation under s.16. The 24h reporting clock on the 3 highest-conviction accounts starts the moment we cross that threshold internally — that happened at 14:30 today.

Pattern match score progression: 0.71 (19-May) → 0.74 → 0.76 → 0.79 → 0.82 (23-May 14:30)

AML alerts trailing 14d: 18 (baseline 4 over 90d; z-score 5.4)

Shared HCMC beneficiary network: 3 of 18 alerts on Tan Phu Electronics + Sai Gon Trading Co.

BNM AMLA s.16: EDD mandatory at 'reasonable suspicion' (internal threshold pattern-match 0.80)

AMLA s.14: 24h STR clock from suspicion confirmation

Approve overlay rules v4.1 deployment Wed 02:00 (Pricing/Treasury moves already locked in for Wed)

Initiate EDD on 3 highest-conviction SME accounts immediately (4 hours before 24h STR clock starts)

Brief BNM AMLA liaison desk informally about pending overlay deployment and STR filings

If we don't deploy by Wed 02:00, 24h STR clock on the 3 accounts pushes filing to Thu — still within regulation but creates a paper trail of delay that could attract supervisory questions during the Pillar 2 review (8-Jun).

Alert volume sustained above 3x baseline for 6 days; pattern match score crossed 0.80 today.


Tadau Kaamatan 30-May to 1-Jun. Treasury wants to defer the CIT booking by 48h to see if early withdrawal pattern matches the 3.5x multiplier — saves RM 60k in CIT premium fees if pattern softens.

Defer 48h — early withdrawal pattern still tracking 3.4x, not yet justifying full RM 38M loading

ATM withdrawal volume on trailing 5 days is +2.1x baseline — below the 3.5x historical Tadau multiplier. Two interpretations: (a) the spike will come later in the week as it did in 2024, or (b) it's a softer year due to lower oil palm prices in Sabah (CPO at RM 3,820/MT, -8% YoY) reducing rural disposable income. Treasury proposes 48h defer to Mon, then commit either RM 38M (full load) or RM 28M (90% load) depending on weekend pattern.

Trailing 5-day Sabah ATM withdrawal multiplier: 2.1x (vs historical 3.5x for the equivalent T-7 day pre-Tadau)

CPO price: RM 3,820/MT (-8% YoY) — Sabah rural disposable income proxy

G4S CIT premium: RM 60k saved if booking lands 3-day lead vs 5-day lead

2024 pattern: spike landed T-4 day (Thu before Tadau Friday) — analogue suggests 27-May trigger

Cash-refusal risk: bounded at RM 0.8M if we under-load by 25% and need emergency Sat top-up

Hold CIT booking decision until Mon 10:00 (review weekend withdrawal print)

Pre-clear G4S Sabah on contingent 3-day-lead booking option (premium RM 60k)

Brief Branch Manager Kota Kinabalu on contingent over-counter cash plan

15% probability we under-load and trigger cash-refusal events Sat-Sun, costing RM 0.8M in customer trust + RM 50k emergency CIT. Mitigated by KK main branch vault overflow buffer.

Volume crossed 5M trigger 22-May but multiplier still below historical Tadau pattern.


Attrition risk score at 84; CRM social-signal scrape shows OCBC continuing outreach to 4 more SME RMs in Penang. Counter-offer window closing.

OCBC outreach widening — 4 more Penang RMs now on the scrape — 72h window to lock retention

The 3 confirmed resignations on 22-May are the tip; CRM social-signal scrape from 23-May identifies 4 additional Penang SME RMs in active conversation with OCBC recruiters (LinkedIn InMail + 2 lunches logged at OCBC Penang office). Counter-offer policy normally requires HR Committee approval (3-5 working days) — but the 72-hour window before OCBC formalises offers means we need CEO emergency authority. Branch recommends escalating to CEO Mon morning.

Confirmed resignations: 3 (Tan, Lim, Goh; submitted 22-May)

CRM social-signal scrape (23-May 11:00): 4 additional Penang SME RMs in active OCBC conversations

HR Committee normal lead time: 3-5 working days for counter-offer approval > RM 200k

OCBC Penang SME expansion announced 19-May (Bursa filing) — target 25 RM hires by Q3

Aggregate portfolio at risk if all 7 leave: RM 540M deposits + RM 820M lending

Brief CEO + CHRO Mon 08:00 for emergency counter-offer authority (RM 2.8M pool ceiling)

Schedule individual conversations with the 4 'at-risk' RMs by Tue (Head of SME + Branch Manager)

Activate top-account warm-handover for the 3 confirmed leavers (relationship director shadow visits)

If counter-offer authority is not in place by Tue, OCBC formalises offers to the 4 at-risk RMs and another 2-3 confirm departures — pushing portfolio-at-risk from RM 240M to RM 540M.

Concentration risk now actionable — Batu Kawan satellite desk business case ready

Network has had Batu Kawan satellite SME desk on the strategy roadmap since Q4-2025 (deferred for capex). The Penang RM event makes this the right moment to fund — splitting the FTZ corridor between Bayan Lepas and Batu Kawan reduces single-branch concentration and gives us 2 additional RM seats to absorb counter-offer flexibility. Network recommends approval of RM 1.4M capex + opex commitment alongside the counter-offer pool.

Batu Kawan satellite SME desk capex: RM 0.8M (fit-out, IT, signage); opex RM 0.6M Y1

Tenant pipeline: 12 EMS firms signed leases 2025-2026 at Batu Kawan industrial park

Time-to-revenue: 4-6 months to RM 50M deposit balance based on Bayan Lepas analogue

Concentration metric: Penang FTZ single-branch share would drop from 100% to 60-65% within 9 months

BNM branch authorisation: satellite SME desk does not require FSA s.39 (sub-branch designation)

Bundle Batu Kawan satellite desk approval with counter-offer pool to CEO Mon 08:00

Engage MIDA on Batu Kawan industrial park MoU (signed 2024, refresh due Jun-2026)

Pre-screen 2-3 senior SME RM candidates for Batu Kawan lead role (succession planning value)

If Batu Kawan is approved but RM retention fails, the satellite desk runs under-staffed for 2-3 quarters — opportunity cost ~RM 0.4M vs no-build scenario but franchise concentration is still reduced.

sme-book-concentration batu-kawan-tenant-pipeline fsa-sub-branch-designation memory:2024-hsbc-rm-poach mida-batu-kawan-mou

Score breached 70 trigger on 22-May; OCBC Bursa filing 19-May was the inflection point.


BNM MPC minutes (T-3) signal +25bps OPR move; competitor FD board rates already ticked up 18-22bps over the trailing 9 days. Window to reprice 5-year ladder closes Wed 09:00 before BNM 11:00 release.

5Y FD board at 4.05% is 22bps light vs Maybank/CIMB — repricing now captures RM 12.4M NIM over book

Competitor scrape shows Maybank moved 5Y FD from 4.05% to 4.20% on 21-May and CIMB to 4.25% on 23-May. Our retention model puts churn elasticity at -1.8 per 10bps on the 5Y bucket (book RM 8.2bn). Repricing to 4.25% before the BNM MPC release at Wed 11:00 lets us absorb the OPR move into the front book without re-papering the back book, banking the spread for 18 months until the next FRS review.

Competitor 5Y FD: Maybank 4.20% (21-May), CIMB 4.25% (23-May), Public Bank 4.15% (23-May); our board 4.05%

Book at risk: RM 8.2bn across 5Y bucket; trailing 14-day net inflow -RM 184M (first sustained outflow since Q3-2025)

BNM MPC minutes (released 22-May 17:00) — 4 of 7 MPC members flagged 'sticky core CPI' language, OIS implied 88% probability of +25bps

Retention model v3.2: churn elasticity -1.8 per 10bps on 5Y; -0.6 on 12M tenor

NIM uplift modelled: +RM 12.4M over 18-month effective duration at 4.25% board

Reprice 5Y FD board from 4.05% to 4.25% effective Wed 08:00, hold 1Y/3Y tenors flat (avoid cannibalising CASA)

Notify 47,200 5Y-tenor customers with auto-rollover via SMS Wed 09:30; RM-led calls for top 380 balances > RM 2M

Pre-clear with ALCO Tue 16:00; file FRS-9 adjustment memo with Group Finance same day

If BNM holds (12% probability per OIS strip), the 20bps front-book premium becomes a RM 6.8M cost-of-funds headwind for two quarters until the Aug MPC. Mitigated by 30-day pull-back clause and the fact that competitor boards do not retract quickly.

Duration mismatch on banking book widens RM 3.6bn under +25bps — repricing reduces EVE sensitivity by 38%

Banking book duration gap currently 1.4 years asset-heavy; EVE sensitivity at +25bps parallel shift is -RM 218M. Lifting 5Y FD board pulls RM 1.9bn of inflow into the 5Y bucket over the next 6 weeks (per FD ladder model), shortening liability duration by 0.21 years and cutting EVE delta to -RM 135M. LCR sits at 138% (headroom RM 4.2bn over 100% floor), so the funding cost is absorbable.

EVE sensitivity report (22-May): -RM 218M at +25bps parallel; -RM 412M at +50bps

Duration mismatch: assets 4.8y / liabilities 3.4y — gap 1.4y, exceeds internal 1.2y soft limit

LCR 138% (RM 4.2bn buffer over BNM 100% floor); NSFR 116%

FD ladder pull-through model: +20bps board lifts 5Y net inflow RM 1.9bn over 6 weeks (R^2 0.83 vs 2023-2025 backtest)

Basel III IRRBB SOT: 14.2% of T1 (limit 15%) — narrow headroom

Coordinate with Pricing Agent on Wed 08:00 board change; pre-fund RM 800M overnight at KLIBOR + 6 to bridge T+2 settlement

Refresh EVE/NII sensitivity post-reprice Thu morning; circulate to ALCO Fri 14:00

Hold MGS portfolio rebalancing until post-MPC to avoid double duration adjustment

If 5Y inflows undershoot (>20% miss probability if competitors match within 48h), duration shortening stalls and IRRBB SOT breaches the 15% T1 limit — triggering a BNM disclosure under IRRBB CP 2023.

Spread breached 15bps trigger on 21-May; widened to 22bps after CIMB move on 23-May.


4 Klang Valley branches (Bangsar, Damansara Uptown, Mont Kiara, TTDI) average 28% utilisation over trailing 90 days vs network median 71%. Flagship at 1 Utama models +RM 14.6M annualised after one-off RM 8.2M closure cost.

4 branches at 28% utilisation — flagship model recovers RM 8.2M closure cost in 7.2 months

Bangsar, Damansara Uptown, Mont Kiara, TTDI sit within a 4.8km cluster and serve a heavily overlapping customer base (62% of customers transact at 2+ of these branches monthly). Trailing 90-day teller throughput averages 47 transactions/day vs network median 168. The proposed 1 Utama flagship (2,400 sqft, premium wealth + SME segment focus) absorbs 84% of footfall with a 9-minute median drive-time impact for affected customers.

Trailing 90-day teller throughput: Bangsar 52/day, Damansara Uptown 41/day, Mont Kiara 38/day, TTDI 56/day — vs network median 168/day

Customer overlap: 62% transact at 2+ of the 4 branches monthly (CRM analytics, May-2026)

Drive-time impact to 1 Utama flagship: median 9 min, 90th percentile 17 min (Google Maps + traffic profile)

Closure costs: lease break-up RM 4.8M, severance/redeployment RM 2.1M, fit-out flagship RM 1.3M = RM 8.2M one-off

Annualised savings: rent RM 9.4M + opex RM 5.2M = RM 14.6M; payback 7.2 months

Submit BNM branch closure notification under FSA s.39(1) for 4 sites — 90-day notice begins 26-May

Engage MIDA on Bumiputera workforce redeployment commitment (12 of 38 affected staff)

Lock 1 Utama flagship lease (signed term sheet, RM 188k/month, 5+5 years) by Wed

12% probability of MP/state assembly intervention given 2 of the 4 branches sit in marginal DAP seats; could delay closure by 3-6 months. Mitigated by Bumiputera redeployment commitment and 90-day customer transition plan.

38 staff impact — 24 redeployable to flagship + 9 to Sunway/Subang, 5 voluntary separation

Across the 4 branches: 38 staff (4 BMs, 6 SMEs, 12 RMs, 16 tellers/CSOs). Flagship model needs 24 (1 BM, 4 SME, 8 RM, 11 teller/CSO). 9 absorbable into Sunway Pyramid and Subang Jaya branches (both at 84-91% utilisation, currently flagged for hiring). 5 likely voluntary separation under VSS at ~6 months' pay. Union (NUBE) pre-engagement done 21-May; tone constructive subject to redeployment guarantee.

Headcount affected: 38 (4 BM, 6 SME RM, 12 retail RM, 16 teller/CSO)

Flagship roles: 24 (1 BM, 4 SME, 8 RM, 11 teller/CSO)

Sunway Pyramid utilisation 91% (open req: 4 teller, 1 SME); Subang Jaya 84% (open req: 3 RM, 1 teller)

NUBE pre-engagement meeting 21-May minutes: constructive subject to redeployment guarantee for non-VSS staff

VSS cost estimate: 5 staff × 6 months avg pay = RM 1.4M (within RM 2.1M severance budget)

Issue individual redeployment letters to 24+9 staff by 28-May; VSS offer to remaining 5 by 30-May

Coordinate with HR on T+30 transition training (premium-segment skill uplift for flagship RMs)

Schedule NUBE formal consultation 27-May 10:00 ahead of FSA s.39 filing

If NUBE shifts position post-consultation (15% probability based on 2024 JB precedent), VSS terms may need to lift 0.5-1.5 months' pay equivalent — adds RM 0.2-0.6M to closure cost but does not change payback materially.

Cluster utilisation sustained below 30% for 7 consecutive days — 50% network trigger threshold breached since Feb.


23 AML alerts in trailing 14 days on Johor→Vietnam SME corridor (vs 4-alert 90-day baseline); pattern matches FATF typology TM-2024-07 (trade-based ML via electronics resale).

23 alerts vs baseline 4 — Johor→Vietnam electronics corridor matches FATF TM-2024-07 typology

AML model fired 23 alerts in trailing 14 days on SME accounts in the Johor→Vietnam electronics resale corridor, up from a 90-day baseline of 4. Common pattern: structuring just below the RM 50k CTR threshold, 24-72h cycle from receipt to onward wire, beneficiary network overlap (4 of 23 accounts share 2 beneficiaries in Ho Chi Minh City). Matches FATF typology TM-2024-07 (trade-based ML via re-exported consumer electronics). Recommend overlay rules to lift alert sensitivity on this corridor and trigger enhanced due diligence (EDD) on 47 SME accounts.

AML alerts trailing 14d: 23 (baseline 4 over 90d; +475% deviation, z-score 6.8)

Structuring pattern: 78% of flows in RM 42-49k band, RM 50k CTR threshold avoided

Beneficiary overlap: 4 of 23 alerts share 2 HCMC beneficiaries (Tan Phu Electronics, Sai Gon Trading Co.)

FATF typology TM-2024-07 (Feb-2024): trade-based ML via consumer electronics re-export — pattern match score 0.84

BNM AMLA s.14 reporting clock: 24h from suspicion confirmed; CTR threshold RM 50k under AMLA/CFT 2001

Deploy overlay rules v4.1 to AML model Wed 02:00 (lifts sensitivity on Johor→Vietnam SME corridor; 18% expected alert volume increase)

Issue EDD instructions to relationship managers for 47 SME accounts by Wed 17:00 (KYC refresh + source-of-funds verification)

File defensive STR with BNM FIED for the 4 highest-conviction accounts by 24h clock (Thu 17:00)

Overlay rules will produce ~18% more alerts network-wide for 30 days post-deploy, straining FCC ops capacity (currently at 84% load). 6% probability of false-positive surge requiring rule tuning within 7 days, but BNM AMLA penalty exposure (avoided RM 9.1M based on prior comparable case) dominates the cost-benefit.

Daily alerts running 3-5x baseline (~1/day) for 7 consecutive days.


Tadau Kaamatan long weekend (30-May to 1-Jun) historically drives 3.4x ATM withdrawal volume in Sabah branches. Cash-in-transit (CIT) booking deadline closes Tue.

Sabah ATM network needs RM 38M top-up by Thu — CIT booking deadline Tue 17:00

Tadau Kaamatan (Sabah harvest festival) drives sustained ATM withdrawal spike: 2022 +3.2x, 2023 +3.4x, 2024 +3.6x, 2025 +3.5x vs baseline. 28 Sabah branch ATMs need RM 38M aggregate top-up to avoid cash-out events over the 3-day weekend. CIT vendor (G4S Sabah) requires booking 5 working days ahead — Tue 17:00 deadline. Single-agent decision; Branch coordinated on routing only.

Historic Tadau weekend ATM withdrawal multiplier: 3.2x (2022), 3.4x (2023), 3.6x (2024), 3.5x (2025)

28 Sabah ATMs across 12 branches (Kota Kinabalu, Tawau, Sandakan, Lahad Datu, Keningau, Kudat)

Aggregate top-up requirement: RM 38M (baseline RM 11M loading covers normal week)

G4S Sabah CIT booking deadline: 5 working days ahead → Tue 17:00 for Thu loading

Avoided cash-refusal incidents (historical comp): 2024 had 47 refusal events worth RM 1.8M in customer trust + media risk

Book G4S CIT for RM 38M loading across 28 ATMs Thu 06:00-14:00 by Tue 17:00

Pre-stage RM 5M overflow at Kota Kinabalu main branch vault for Sat top-up if needed

Confirm BNM cash centre Kota Kinabalu has buffer (last drawdown 19-May, RM 22M)

8% probability of CIT vehicle availability constraint over Tadau (G4S also serves competitor banks); mitigated by 5-day lead booking. Cash-refusal cost (RM 1.8M historical) plus PIDM customer-trust survey signalling dominates the upside.

Withdrawal volume ramping into Tadau Kaamatan window; trigger threshold crossed 22-May.


3 senior SME RMs in Penang (Bayan Lepas hub) submitted resignation letters Fri 22-May for OCBC SME segment expansion. Combined portfolio RM 240M across 47 manufacturing SMEs in the FTZ corridor.

47 SME accounts at risk — 3 RMs trained the relationships personally, no warm handover in flight

The 3 RMs (RM Tan, RM Lim, RM Goh; combined 22 years at the bank, 14 of those in Penang FTZ) carry portfolios worth RM 240M across 47 manufacturing SMEs in the Bayan Lepas free trade zone — concentrated in semiconductor, EMS, and medical device assemblers. Customer-loyalty data shows 68% of these accounts have single-RM-only relationship history (no shadow coverage). OCBC's offer letter (leaked via CRM social signal) includes 1.6x base salary + portfolio-portability bonus. Realistic portfolio defection scenario is 28-35% over 90 days = RM 6.2M revenue at risk.

3 RMs resigned 22-May with 30-day notice (last day 22-Jun)

Combined portfolio: RM 240M deposits + RM 380M lending across 47 SME accounts

Single-RM-only relationship: 68% of accounts (32 of 47) — no shadow RM coverage in CRM

OCBC offer terms (CRM social-signal scrape): 1.6x base + portfolio-portability bonus + Penang regional title

Historic comparable: 2024 HSBC poach of 2 RMs led to 34% portfolio defection in 90 days (RM 84M lost)

Convene CEO + Head of SME + CHRO Tue 14:00 for counter-offer authority and customer retention budget

Activate 'top-account swarm' protocol: assign senior SME head + relationship director to top 8 SME accounts within 48h

Approve retention bonus pool of RM 1.8M (75% of comparable HSBC retention case) pending CEO sign-off

60% probability we lose 25-35% of portfolio over 90 days if counter-offer is not extended in 72h. Higher-order risk: 2-3 additional Penang SME RMs may follow if the bank is seen as not defending the franchise — would extend loss to RM 12-15M.

Penang FTZ SME franchise concentration risk — single-corridor exposure now visible

This event surfaces a structural network design issue: 47 of our top FTZ SME accounts are managed by 3 RMs in one branch (Bayan Lepas). Network strategy view: the franchise should have been carved into 5-6 RM portfolios with overlapping coverage, not 3. Beyond the immediate retention play, Network recommends a 90-day plan to restructure Penang SME coverage into shadow-RM pairs (every top-50 account gets a primary + shadow RM) and to open a satellite SME desk at Batu Kawan to relieve Bayan Lepas concentration.

Penang FTZ SME book RM 620M total — 47 accounts (RM 240M) under 3 RMs = 39% concentration

Network-wide SME RM book-size average: RM 38M (these 3 carry RM 80M each = 2.1x average)

Batu Kawan industrial expansion: 12 new EMS tenants signed leases 2025-2026, RM 4-8M deposit potential each

Shadow-RM coverage standard (Group SME Strategy 2024): primary + shadow for accounts > RM 5M; currently only 32% compliant in Penang

Lease cost Batu Kawan satellite SME desk: RM 38k/month (3 RMs + 2 support)

Commission 90-day Penang SME franchise restructure plan (deliverable by 14-Jun)

Approve in-principle Batu Kawan satellite SME desk (operational target 1-Aug)

Re-survey shadow-RM coverage across all Penang SME accounts > RM 5M by 7-Jun

Even if we retain the 3 RMs, the concentration risk remains until shadow-RM coverage is implemented. 25% probability of a second poach attempt within 6 months by Maybank Islamic SME or RHB if franchise restructure is not visible to the market.

Resignation event 22-May pushed score above 70 trigger; second-order risk to remaining RMs now elevated.